Table of Contents
MANAGE OUR IMPACT RESPONSIBLY
3
48
OVERVIEW
Message from the President and CEO About this report About us Our approach to sustainability Identifying our priorities
....................... 4 ......................................................... 5 ....................................................................... 6 .................................... 7 ............................................. 8
Our developing approach to climate change Environmental impact of our operations Social and environmental risk management Responsible procurement
.......... 49 .................. 51 ............ 54 ......................................... 55
MAINTAIN A FOUNDATION OF TRUST
56
10
SUPPLEMENTAL REPORTING
............................................... 11 ..................................... 15 .............................................................. 17 ................................. 18
Corporate governance Business ethics and integrity Human rights Data privacy and cybersecurity
TCFD report Public Accountability Statement SASB index
............................................................... 57 ............................. 64 ................................................................. 67
73
OBSESSED WITH YOUR SUCCESS 20
APPENDICES
....................................................... 21 ..................................................... 25 ........................................ 29 .............................................. 37 ............................................ 42 ............................ 47
Client experience Financial inclusion Team member experience
........................... 73
How we listen to our stakeholders Independent practitioner’s limited assurance report Forward-looking statements
....................................................... 74 ..................................... 76
Diversity and inclusion Community investment Sustainable finance and products
2 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Overview
In this section • Message from the President and CEO • About this report • About us • Our approach to sustainability • Identifying our priorities
Sanjay Chatrath, CWB Mississauga Banking Centre
3 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Message from the President and Chief Executive Officer
Guided by our values, culture and strategy, we are committed to manage our environmental impact responsibly and address important social issues while maintaining the trust of our stakeholders with the highest standards of governance, ethics and integrity. In 2022, we engaged our stakeholders to help us prioritize our most important environmental, social and governance (ESG) factors and deepen our understanding on where we can create the most value. Small- and medium-sized business owners are the heart of the Canadian economy and our core focus as the best full-service bank for business owners and their families. We are obsessed with the success of our clients and provide them with an unrivaled client experience by pairing enhanced digital tools with the personalized and differentiated service we are known for. In 2022, we initiated the roll-out of our new, scalable small business digital banking offering, which we believe will fill a gap in Canada’s financial services industry. Through our digital transformation, we continue to strengthen our cybersecurity and data privacy practices to manage evolving threats and maintain the trust our clients. The delivery of an unrivaled client experience is supported by our talented teams and collaborative culture. CWB is a destination for top talent with an environment where everyone feels a strong sense of belonging and has equitable opportunity to succeed. In a highly competitive talent market, we are recruiting and retaining the right people with a continuous focus on learning and development, mentorship and coaching, and career advancement opportunities. We continue to navigate the evolution of remote and hybrid work arrangements, while also recognizing the importance of human connection to sustain our culture. As a result of our unwavering commitment to our People First value, in 2022 we were recognized by Great Place to Work Canada ® as one of the top 20 Best Workplaces TM in Canada and one of the Best Workplaces TM for Hybrid Work. We recognize that we have a part to play in Canada’s transition to net-zero emissions. Our developing approach to climate change begins with a focus to ensure that our operations are managed responsibly to reduce our direct impact on the environment. We are committed to help our clients achieve their sustainability goals as we work collaboratively to support
the transition to a lower carbon economy. As we move forward, our climate strategy will strike a balance between the urgency to act and the need to develop a credible approach that supports our long-term strategy. Sustainable growth is our path forward. The steps we have taken through 2022 are foundational to the further development of our approach to sustainability, including a focus to address the impacts of climate change, that will drive positive change in our communities and create value for our clients, our people and our shareholders. We will continue to build on our existing sustainable practices, focus on priority topics that present new or evolving opportunities or challenges, and provide transparent disclosures as we progress with purpose.
Chris Fowler, President and CEO CWB Financial Group
4 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
About this report This Sustainability Report includes information about Canadian Western Bank and its subsidiaries (collectively, CWB) and outlines our activity and performance related to ESG factors that are most important to our stakeholders. Unless otherwise stated, the information contained within this report pertains to our fiscal year ended October 31, 2022, and all amounts are reported in Canadian dollars.
Reporting to the Chief Financial Officer (CFO), our Sustainability team is responsible for the development of this report, which was reviewed by our ESG Steering Committee, Disclosure Committee and Board of Directors prior to its release.
PUBLIC ACCOUNTABILITY STATEMENT
This report includes our Public Accountability Statement, which describes the contributions we made to the Canadian economy and society in fiscal 2022, in alignment with the regulatory requirements outlined in section 627.996 of the Bank Act . Refer to page 64 for further details.
REPORTING STANDARDS AND FRAMEWORKS
We provide transparent disclosures on our approach to sustainability, supported by a phased adoption of several voluntary reporting frameworks, including the: • Task Force on Climate-related Financial Disclosures (TCFD) recommendations (refer to page 57 ); and, • Sustainability Accounting Standards Board (SASB) standards (refer to page 67 ). We will continue to enhance our disclosures as we advance our approach to sustainability and as related reporting regulations and stakeholder expectations evolve.
Simon Wong, CWB Trust Services
We publish a range of materials with information about our approach to sustainability and relevant ESG factors. The following publications are referenced throughout this report and can be found on CWB.com:
INDEPENDENT LIMITED ASSURANCE
We obtained limited assurance from KPMG LLP (KPMG) on our Scope 1 and 2 greenhouse gas (GHG) emissions figures disclosed on pages 51 and 63 . Refer to page 74 for KPMG’s Independent Limited Assurance Report.
• Annual Report • Equity Report Narrative • Management Proxy Circular
WAYS TO REACH US
We welcome your feedback on this Sustainability Report. Please direct your questions and comments to sustainability@cwbank.com .
Our previous Sustainability Reports can be found at www.cwb.com/en/sustainability-reports
5 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
About us CWB is the only full-service bank in Canada with a strategic focus to meet the unique financial needs of businesses and their owners. We provide our nation-wide clients with full-service business and personal banking, specialized financing, comprehensive wealth management offerings, and trust services. Clients choose CWB for a differentiated level of service through specialized expertise, customized solutions, and faster response times relative to the competition. Our people take the time to understand our clients and their business, and work as a united team to provide holistic solutions and advice. We are firmly committed to the responsible creation of value for all our stakeholders and our approach to sustainability will support our continued success.
OUR VALUES
PEOPLE FIRST
RELATIONSHIPS GET RESULTS
EMBRACE THE NEW
THE HOW MATTERS
INCLUSION HAS POWER
Change is everywhere. We seek out new ideas and are committed to continuous learning. We know that better is always possible.
How we do things is as important as
Diverse teams unleash new ideas and perspectives. We are aware of our own biases. We are proud of who we are, and we are allies for those around us.
Caring people are the key to our success. We work as a team and support one another. We always treat each other with respect and have the courage to be candid.
Clients choose CWB for the best experience. We build relationships proactively, with intention and consistency. Our results depend on it.
what we do. We take ownership, and move with urgency and efficiency. We always
act with integrity, and balance risk and reward.
STRATEGIC DIRECTION
We invest in key products, services, processes, and culture to provide an unrivaled client experience, be a career destination for top talent, and optimize our business to deliver enhanced shareholder value. Our strategic direction confirms our path ahead and outlines our key priorities to further strengthen our position as the best full-service bank for business owners in Canada.
ORGANIZATIONAL GOALS
Unrivaled client experience (Clients)
Destination for top talent (People)
Optimize our business (Investors)
OUR FOCUS
Inclusive culture & employee experience
AIRB supported by a scalable operating model
Elevated digital & payments capabilities
Differentiated wealth management experience
Lower-cost funding model
Market & segment expansion
OUTCOMES
Accelerated growth of full-service client relationships
Strong core operating performance with meaningful expansion of return on equity
6 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Our approach to sustainability Our values, culture and strategy guide our approach to sustainability, which addresses the ESG factors that are most important to our clients, people, investors and communities. Our approach is focused to support the ongoing success of our clients and we remain committed to long-term value creation for all our stakeholders and sustainable growth for our business. During 2022, we further developed our focused approach to sustainability, engaging our stakeholders to deepen our understanding of the ESG factors that they feel are most impactful to our business, or where our operations could have a significant impact on society and the environment. Through this process, which is further discussed on the next page, we identified the following sustainability priorities within three areas of focus.
MAINTAIN A FOUNDATION OF TRUST Ensure the highest standards of governance, ethics and integrity to maintain the trust of our stakeholders Priorities • Corporate governance • Business ethics and integrity • Human rights • Data privacy and cybersecurity
OBSESSED WITH YOUR SUCCESS Contribute to the success of our clients and their families, our people, and their communities in pursuit of a sustainable and inclusive future Priorities • Client experience • Financial inclusion • Team member experience • Diversity and inclusion • Community investment • Sustainable finance and products
MANAGE OUR IMPACT RESPONSIBLY Responsibly manage our social and environmental impact, and support Canada’s transition to net-zero emissions Priorities • Climate change • Environmental impact of our operations • Social and environmental risk management • Responsible procurement
Moving forward, we will continue to embed sustainable practices within our operations that are aligned with our strategy and prudent approach to risk management, and will help our clients achieve their sustainability goals. As we advance our approach, we will continue to focus on our existing priorities as well as topics that present new or evolving opportunities or challenges. We will engage our people to advance a collective sense of purpose and amplify our impact. We are committed to provide our stakeholders with transparent reporting on our progress and performance as our approach evolves.
7 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Identifying our priorities
ENGAGING WITH OUR STAKEHOLDERS
Continuous engagement with our clients, people, investors and communities is critical to our success. Through ongoing communication and collaboration, we maintain a solid understanding of the expectations of our diverse stakeholders to support strong relationships and ensure that our business activities align with their evolving needs. Refer to the How we listen to our stakeholders section of this report for examples of the communication channels we use to gather feedback and respond to our stakeholders. During 2022, we also engaged a broad range of our internal and external stakeholders to complete a comprehensive materiality assessment to identify and prioritize our most significant ESG factors. This assessment will support the ongoing advancement of our focused approach to sustainability and inform the content of our reporting and disclosures. Our assessment was supported by an independent consulting firm and completed based on the Global Reporting Initiative (GRI) approach, which is a commonly used framework.
Chris Fowler, AGM Live Event, CWB Financial Group
Our materiality assessment involved:
1. Identifying potential ESG factors that could impact our business, or where our operations could have a significant impact on society and the environment. To
3. Prioritizing our most material ESG factors based on inputs gathered. The materiality assessment process and final matrix were reviewed by our ESG Steering Committee and Board of Directors.
2. Gathering input from our stakeholders. We surveyed our clients, people, investors, suppliers, community partners and Board of Directors to gain a broad understanding of their perspective on the importance of each ESG factor. We also conducted in-depth interviews with numerous stakeholders to gain a deeper understanding of their perspectives on relevant ESG factors and the areas where we can create the most value.
determine our list of potential ESG factors, we considered stakeholder expectations, peer benchmarking, industry trends and best practices, requirements within voluntary and regulatory reporting frameworks, and attributes assessed by credit and ESG rating agencies.
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Table of Contents
Maintain a foundation of trust
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
OUR PRIORITIES
Our priority ESG factors, which are discussed in the respective sections of this report, are as follows:
Foundational priorities
Foundational priorities are fundamental to our success
Client experience
and include: • Corporate
Team member experience
Diversity and inclusion
governance
• Business ethics and integrity
Data privacy and cybersecurity
Human rights
Community investment
Financial inclusion
Social and environmental risk management
Climate change
Sustainable finance and products
Environmental impact of our operations
Responsible procurement
Impact on CWB
MAINTAIN A FOUNDATION OF TRUST
MANAGE OUR IMPACT RESPONSIBLY
OBSESSED WITH YOUR SUCCESS
9 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust Ensure the highest standards of governance, ethics and integrity to maintain the trust of our stakeholders
In this section • Corporate governance • Business ethics and integrity • Human rights • Data privacy and cybersecurity
• Formed an ESG Steering Committee and further integrated ESG oversight into the mandates of the Board of Directors and its Committees • 60% of Board director nominees are women, including our Board Chair, and 20% identify as Black, Indigenous
or racialized persons, achieving our diversity targets well ahead of schedule • Continued to enhance our cybersecurity program and security solutions for our clients, including multi-factor authentication and centralized identity management
Akilah Nelson, CWB Markham Banking Centre
10 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Corporate governance
We maintain the trust of our stakeholders through strong corporate governance practices supported by a Board of Directors with diverse experiences and perspectives. Our policies and practices foster ethical conduct, promote responsible business practices, and ensure CWB is governed with a focus to build long-term value for our stakeholders.
ABOUT OUR BOARD OF DIRECTORS
Canada, an organization that supports the goal of having 30% of corporate board positions held by women. In 2020, the President and CEO signed the BlackNorth CEO Pledge, committing CWB to specific actions and targets designed to end anti-Black systemic racism. With current director nominees, if elected, 60% of the Board will be comprised of women, surpassing the targets for women in both our Corporate Governance policy (target of 40%) and the 30% Club. Further, 20% of Board directors identify as Black, Indigenous or racialized persons, surpassing the targets in our Corporate Governance policy (target of 5%) and our BlackNorth CEO Pledge commitment, well in advance of the 2025 deadline. Strong governance practices Our Board works closely with management to ensure our governance approach incorporates evolving industry trends, regulatory expectations and global best practices. We ensure that our governance policies meet or exceed the requirements of our regulators. We consider, and where appropriate will adopt, new corporate governance best practices put forward by governance institutions, industry groups, and groups that represent the interests of our shareholders and other stakeholders.
Our Board’s primary responsibilities are to provide oversight of CWB’s risk appetite, culture, strategy, capital plans and key policies, and to provide challenge, advice and guidance to senior management. To fulfill its mandate, certain responsibilities are delegated to its standing committees, which include the Audit, Governance and Conduct Review (GCR), Human Resources (HR), and Risk Committees (collectively, the Committees). Effective Board composition Our Board is composed of independent directors and our CEO, who have diverse backgrounds and complementary experience and expertise to ensure robust oversight. During director recruitment and succession planning, the GCR Committee seeks out suitable candidates and assesses the potential candidate’s experience and expertise against the needs of the Board and its Committees. The GCR Committee uses an expertise and skills matrix to assess our directors and regularly analyzes whether the Board has the appropriate composition. Board diversity commitments On behalf of CWB, the Chair of the Board and the President and CEO have signed on as members of the 30% Club
CWB is actively working to promote inclusive and sustainable growth for our business, our clients, our people and the communities in which we operate. We are proud of the progress we have made to-date and are committed to support and engage with management as they continue to develop and implement CWB’s approach to sustainability.” - Sarah Morgan-Silvester Chair of the Board
11 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Corporate governance snapshot
Appropriate Board size
10 director nominees
9 of 10 director nominees are independent (1)
Board independence
Formal mandate for Board, Board Committees and Board Chair
P
Separate Chair and CEO positions
P
Annually elect directors
P
Elect directors individually (not by slate)
P
Majority voting policy for directors
P
60% of director nominees are women 20% of director nominees identify as Black, Indigenous or racialized persons 50% of committee Chairs are women
Board diversity
Share ownership requirements for directors and executives
P
Formal mandates for the independent Chair of the Board and committee Chairs, and position description for the CEO
P
Retirement age for directors
75
Average tenure of director nominees
7.1 years
Orientation and continuing education program for directors
P
Annual advisory vote on executive compensation
P
Formal assessment process for the Board, Chair of the Board and committee Chairs
P
Shareholder engagement program
P
(1) Under the Bank Act , the CEO is required to serve as a director of CWB. The Chair of the Board is an independent director. Separating the roles of CEO and Chair of the Board allows the Board to effectively oversee management, enhance accountability, and avoid potential conflicts of interest.
Refer to our 2022 Management Proxy Circular for more information about our approach to corporate governance. Formal mandates for the Board and its Committees can be found on our website at: www.cwb.com/corporate-governance.
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Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
SUSTAINABILITY GOVERNANCE
To support the advancement of our approach to sustainability, during 2022, we enhanced our Board and management oversight frameworks. We established an ESG Steering Committee and updated the mandates of the Board and its Committees to further reflect specific responsibilities related to relevant ESG factors.
Board Oversight
Board of Directors
Provides oversight of our risk appetite, culture and strategy, including the development and execution of our approach to sustainability and related public disclosures in the Sustainability Report and Public Accountability Statement.
Risk Committee
Audit Committee
HR Committee
GCR Committee
Provide oversight of ESG factors that are specific to Committee mandates.
Management Oversight
Executive Team
Responsible for the development and implementation of our strategic direction, including our approach to sustainability.
ESG Steering Committee
Executive Risk Committee (including subcommittees)
Provides oversight of the development and implementation of our approach to sustainability, with integration to our broader corporate strategy.
Provides oversight of risks that arise in executing our strategy, including direct social and environmental risks, and the indirect impact of these factors on other risk types.
Disclosure Committee
Provides oversight of public disclosures, including the Sustainability Report.
Execution and Socialization
Business units and corporate teams, cross-functional committees and working groups
Sustainability team
13 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Board responsibilities Our Board is responsible for overseeing the development and execution of our approach to sustainability and related disclosures included within our Sustainability Report and Public Accountability Statement. Each of our Board directors has experience in sustainability matters, including environmental and social issues, and/or corporate governance principles and practices. Our Board receives ongoing education and quarterly reporting to facilitate discussion of current and emerging trends, risks and opportunities. As sustainability requires a multidisciplinary approach, the Committees provide oversight of specific ESG factors. – The Risk Committee oversees our approach to principal risks and the continued integration of material social and environmental risk factors within the Risk Management framework. – The Audit Committee oversees our financial reporting, including disclosures related to material ESG factors incorporated into the annual financial statements, annual Management’s Discussion and Analysis (MD&A) and Annual Information Form. – The HR Committee oversees our human capital management strategy and aspects of workplace culture, including diversity, equity and inclusion, and employee health, safety and well-being. – The GCR Committee oversees our corporate governance policies, practices and standards that promote ethical conduct throughout our organization as well as the allocation of sustainability oversight across the Committees. Management responsibilities In 2022, we established an ESG Steering Committee to oversee the design and execution of our approach to sustainability. The ESG Steering Committee consists of each member of our Executive team, and is supported by our Sustainability team, who engages with internal and external stakeholders and works closely with our business units and corporate teams to establish appropriate working groups tasked with the development of various components of our approach to sustainability. Our Executive Risk Committee provides oversight of our developing approach to identify, assess, monitor, and report on social and environmental risks. In addition to their participation in the ESG Steering Committee and Executive Risk Committee, members of our Executive team have specific accountabilities related to our approach to sustainability. For example, our Chief People & Culture Officer is accountable for our approach to diversity, equity and inclusion and our Chief Information Officer is responsible for cybersecurity programs.
Embedding sustainability within executive compensation Our executive compensation philosophy aims to attract and retain a team focused to develop and execute our strategic direction, and deliver strong outcomes for our clients, people, investors and communities. A component of executive variable pay is linked to key ESG factors, such as client satisfaction, team member engagement and diversity and inclusion across the organization. The ongoing development and execution of our approach to sustainability, including a climate transition plan, was included in the performance criteria of the performance share units (PSUs) granted under our executive long-term incentive plan (LTIP) this year. As our approach to sustainability evolves, we will continue to explore further integration of ESG factors into our compensation programs.
Refer to page 33 of our 2022 Management Proxy Circular for further information about our executive compensation program.
Kelly Blackett, Chief People & Culture Officer CWB Financial Group
Refer to our TCFD report on page 57 for further information on Board and management oversight responsibilities specifically related to our approach to climate change.
14 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Business ethics and integrity
Our culture is based on the principles of integrity and accountability. Our commitment to ethical business practices is foundational to our reputation and ability to build and maintain strong relationships with our clients, people, investors and communities.
OUR APPROACH
contributes to an organization where we are all proud to work, where clients want to do business, and where shareholders are confident to invest.
The GCR Committee oversees our ethics program, which is managed by an internal Ethics Committee comprised of senior leadership and chaired by the Chief Ethics Officer. All directors, officers and team members are held to a high ethical standard and are required to attest to our Code of Conduct, titled Living our Values, on an annual basis. Our Code of Conduct is based on proactive integration of our corporate values into our activities so that each team member
OUR CODE OF CONDUCT
Our Code of Conduct, which is reviewed and approved annually by the Chief Ethics Officer and the Ethics Committee and approved by the Board of Directors, sets out clear expectations for our team members related to:
– Demonstrate personal integrity. – Support an inclusive work environment free of discrimination and harassment. – Promote a safe and healthy work environment.
Living our values at work
– Avoid conflicts of interest and disclose potential conflicts of interest. – Avoid gifts and entertainment that may impact business decision-making. – Maintain complete and accurate information in our documents. – Exercise responsible sales practices to deal fairly and honestly with our clients and act in their best interests. – Comply with anti-bribery and anti-corruption policies. – Comply with anti-money laundering, terrorist financing and economic sanctions policies. Our Know Your Customer (KYC) policies, standards and practices are an essential risk management tool, and we comply with all regulatory requirements during our due diligence processes. – Use company assets and resources appropriately. – Safeguard the confidential information of our clients and team members. – Protect material non-public information and adhere to share trading restriction policies. – Adhere to workplace policies related to communications and social media as well as email, internet and information systems use.
Living our values in business
Living our values for our investors
– Avoid political contributions and political involvement on CWB’s behalf. – Adhere to specific requirements related to lobbying activities.
Living our values in our communities
Refer to our Code of Conduct to learn more about our approach to business ethics and integrity.
15 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
FOSTERING A SAFE ENVIRONMENT TO RAISE CONCERNS
TRAINING AND AWARENESS
Training is a crucial aspect of our ethics-based culture that provides our team members with knowledge to understand their responsibilities to act with integrity and in compliance with regulatory requirements. Our ethics program sets out mandatory training requirements for our team members and hosts a periodic Ethics Week to shine a spotlight on ethics- related topics and practices. Training requirements address a wide range of topics, including anti-money laundering and anti-terrorist financing, ethics awareness, fraud awareness, operational risk management, economic sanctions laws, workplace harassment and violence prevention, material non-public information and insider training.
Our ethics program provides avenues for our team members and contractors to raise serious ethical questions and concerns, through multiple levels of intervention, including confidential interaction with our embedded Ethics Officers or an anonymous Ethics Hotline, which is managed by a third-party service provider. We protect individuals who raise ethical concerns and retaliation against a person for reporting an issue or participating in an investigation is a serious violation of our Code of Conduct. A summary report of all concerns raised or identified is provided to the Ethics Committee and the GCR Committee on a quarterly basis.
EMBEDDING ETHICAL BEHAVIOUR WITHIN COMPENSATION
Team member performance management and compensation are directly aligned to ethical decision-making and risk management. A significant portion of every team member’s performance rating is based on performance drivers, which include acting with integrity and in line with our values. Further, if an individual at the level of Assistant Vice President, a mid-level management role, or above engages in job-related fraud, ethical misconduct, or a serious violation of CWB policies, the HR Committee may exercise its discretion to recoup previously paid variable cash compensation, require forfeiture of vested and unvested equity-based variable compensation or recoup any realized gains on previously exercised equity-based compensation.
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Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Human rights
Protecting human rights is crucial to building a more equitable, inclusive and sustainable society. In alignment with our culture and values, we support and respect the protection of human rights throughout our operations and across our business.
AN INTEGRATED APPROACH
barrier-free access at our locations, and individualized accommodation plans to remove barriers that may affect our team members’ performance or access to training and development opportunities. To support awareness of commitments and responsibilities, our team members are required to complete training on human rights topics, including workplace harassment and violence prevention and our accessibility program, upon hire and on a regular basis thereafter. Our ethics program provides multiple avenues for our team members and contractors to raise human rights questions and concerns, including confidential interaction with our embedded Ethics Officers and an anonymous Ethics Hotline. In 2022, we initiated the development of our Supplier Code of Conduct, which is expected to be finalized in 2023. The principles of our Supplier Code of Conduct will be aligned with our internal Code of Conduct and set out our expectations for our suppliers to act in an ethical manner and in compliance with applicable laws, including employment, labour, non- discrimination and human rights legislation.
We operate solely in Canada and comply with all federal, provincial and territorial human rights laws and standards, including the Canadian Human Rights Act, the Canadian Charter of Rights and Freedoms and the Canada Labour Code. We are guided by our values and Code of Conduct to promote an inclusive and safe work environment that is free of discrimination and harassment based on race, colour, ancestry, national or ethnic origin, pardoned criminal conviction, religious beliefs, gender, age, disability, marital status, family status, source of income, gender identity or expression, genetic characteristics or sexual orientation. We are an equitable employer and follow a merit-based approach in all areas of employment, including recruitment, hiring, career advancement, and access to benefits and opportunities. Under our accessibility program, we strive to create an environment where all our team members and clients have access to the support and resources they need to succeed. This includes tailored communication strategies,
Our commitment to protect human rights is integrated into our policies, programs and practices, including our:
• Code of Conduct • Recruitment and talent management practices • Accessibility program
Refer to the Business ethics and integrity , Financial inclusion (Creating accessible facilities, services and products) and Diversity and inclusion sections to learn more.
17 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Data privacy and cybersecurity
Our stakeholders depend on us to protect the data they entrust us with. As we continue to use innovative technologies to deliver better services and automate and digitize processes to attract clients and team members, strong data privacy and cybersecurity programs are key to our success.
DATA PRIVACY
CYBERSECURITY
Our approach Our comprehensive Privacy Compliance framework establishes the principles of our organization-wide privacy management program to protect the personal information of our clients and comply with applicable legal and regulatory requirements. Our Chief Privacy Officer oversees our privacy management program and is responsible to set and monitor the effectiveness of related policies and procedures. The GCR Committee oversees privacy risk management and receives regular reporting as part of its oversight responsibilities. Incidents involving suspected or actual breaches of privacy are documented and investigated by our Privacy Office. If a privacy breach has occurred, our team follows established procedures to limit its impact, understand the root cause of the incident, ensure that the issue is remediated and take preventative steps to avoid recurrence. Where appropriate, we notify applicable regulators and impacted individuals. Our privacy management program extends to third-party service providers, and we assess their privacy management practices and controls prior to providing them with any personal information of our clients. Once satisfied with the service provider’s procedures and safeguards, we will only provide them with the personal information required to deliver contracted services. Training and awareness We make privacy a key focus for our team members and take steps to ensure they are aware of privacy-related regulatory obligations relevant to their role, know how to comply with those obligations, and are accountable to achieve effective compliance. All team members are required to undergo privacy training as part of their onboarding experience, and on an annual basis thereafter. Privacy principles, such as only accessing information for legitimate business purposes, are also embedded in our Code of Conduct, which applies to all our directors, officers and team members.
Our approach Our cybersecurity program is a mature practice, influenced by well-recognized industry security frameworks. Our program follows the National Institute of Standards and Technology (NIST) framework and aligns to others, including Control Objectives for Information and Related Technology (COBiT) 5, which supports the development, implementation, enhancement and monitoring of information technology governance and information management, and ISO/IEC 27001, an international standard to manage information security. Responsibility for our cybersecurity risk management program resides with the Chief Information Security Officer, with accountability to the Chief Information Officer. Within our three lines of defence model, our Information Security team is responsible for execution of our cybersecurity risk management program, with second and third line oversight provided by the Risk Management and Internal Audit teams. Our Board of Directors provides oversight of our cybersecurity risk management program and receives quarterly reporting on key activities and the ongoing maturation of our program.
Our program is managed by a team of technical and cybersecurity professionals dedicated to proactive
identification, containment, and eradication of cybersecurity threats. We have a comprehensive control framework that is continually assessed for effectiveness using well-established threat intelligence and risk management programs. On an annual basis, our cybersecurity control environment is tested by a third-party service provider. The results of all assessments and progress on any remediation activities are shared with our Board.
Refer to our Privacy Statement to learn more about our privacy management practices, including an overview of how we collect, use and disclose personal information, and the choices clients may exercise in this regard.
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Maintain a foundation of trust
Table of Contents
Obsessed with your success
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Our Chief Information Security Officer is accountable for our comprehensive cybersecurity vulnerability management program. We proactively conduct regular threat analysis activities to identify vulnerabilities in technology and operational processes, and opportunities for remediation. Vulnerabilities are assessed across all technologies and services, and we have defined timeframes around remediation, based on criticality of the affected service and impact or likelihood of exploitation. Incident response
playbooks are rehearsed on a frequent basis and structured continuity plans are in place, including the use of up-to-date and offline storage of critical systems and data. We maintain insurance coverage to help mitigate against certain potential losses associated with cyber incidents. We have a mature third-party security risk management program to evaluate the cybersecurity program effectiveness of all third-party service providers.
During 2022, we: • Enhanced our digital banking platform security features to include multi-factor authentication and centralized identity management; • Continued to leverage innovative technologies around identity and access management to transform the way our team members manage and access applications and services; • Continued to enhance key knowledge and capabilities within our Cyber Security Incident Response team to advance our understanding of the rapidly changing landscape and respond to cyber incidents; and, • Provided Board and executive education sessions, with support from external experts, focused on elevated cybersecurity risks and the development of a cybersecurity risk appetite statement.
Training and awareness The Information Security Office maintains an awareness and education program to inform our team members about their responsibilities with respect to the use of CWB technology and information, and to educate them on the risks of social engineering. The program includes mandatory monthly training requirements, with shifting areas of focus based on current and emerging threats, and monthly simulation tests to assess the effectiveness of our training programs. Areas within the organization that require more focused training are assessed on a regular basis to ensure our team members within higher-risk job functions understand their responsibilities to protect our systems
and information. Each October, we also complete an organization-wide cybersecurity awareness campaign in association with National Cyber Security Awareness month.
Supporting our clients During 2022, we hosted a CWB Expert Series event, facilitated by our Chief Information Security Officer and other industry experts, to provide our clients with insights on building a strong cybersecurity plan, and best practices to manage emerging threats.
19 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Obsessed with your success
Contribute to the success of our clients and their families, our people, and their communities in pursuit of a sustainable and inclusive future
In this section • Client experience • Financial inclusion • Team member experience
• Diversity and inclusion • Community investment • Sustainable finance and products
• 82% of business clients who use CWB as their primary bank have recommended us to others • Launched a small business digital banking offering • Recognized as one of the 20 Best Workplaces TM in Canada by Great Place to Work Canada ® • Our workforce included
60% women, 33% Black, Indigenous or racialized persons and 6% Persons with Disabilities
• Over $2 million invested in community organizations
Monica Ruth, CWB Financial Group
20 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Obsessed with your success
Table of Contents
Maintain a foundation of trust
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
Client experience
Our clients are central to everything we do. We have a differentiated strategy as the best full-service bank for business owners and their families. We are obsessed with the success of our clients and provide them with an unrivaled client experience.
Vyvyan Tsui , Sincerity Law Group, CWB client
Prathavan Venkatraman, Vantage Point Law Office, CWB client
OUR APPROACH
Clients choose us for a differentiated level of service through specialized expertise, customized solutions and faster response times relative to the competition. We deliver an unrivaled client experience by being:
We anticipate our clients’ needs, follow through with speed, and find ways to add more value beyond what they ask for.
We take the time to understand our clients’ needs, tailor solutions unique for their businesses and make them feel like a valued partner.
We are strong and experienced lenders. We offer our clients advice, tools and solutions unmatched in quality and relevance based on our deep industry expertise and knowledge.
Our teams show up as ONECWB for our clients to offer seamless, integrated, full-service products and advice. This creates consistency, scalability and efficiency in our business.
21 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
DIGITAL AND PAYMENTS TRANSFORMATION AND INNOVATION
The banking industry continues to experience rapid digital transformation. We provide an unrivaled client experience by pairing enhanced digital tools supported by our modern technology infrastructure with our traditional focus on personalized service. The continued enhancement of our digital offering provides convenient access to our products and services and, in turn, expands our reach to accelerate our growth of full-service clients. It also ensures we have the capabilities to target key underserved segments, such as small business owners, with customized lending, deposit, and value-add solutions. In 2022, we initiated the roll-out of our new digital banking platform, cwb.digital , for our personal and small business clients. The upgraded platform delivers a modern client experience, with self-serve password reset functionality, enhanced security features, including multi-factor authentication, and an integrated view of credit card transactions for our personal clients. The platform integrates with third-party accounting platforms and provides predictive cash flow analytics functionality to enable small businesses to better understand and manage their cash flow needs.
2023 priorities As we continue to enhance our digital offering, we are creating efficient processes for our clients that allow them to spend less time on administrative tasks and more time adding value to their businesses. Incremental features that will be integrated into cwb.digital in 2023 include the ability to fully on-board business clients digitally and additional tools to help them efficiently assess the financial health of their operations. Digital onboarding capabilities will provide approved small business clients the ability to open accounts, set up online banking and apply for select lending products, online and at their convenience. In 2023, we will also enhance our digital client experience with the introduction of single sign-on access to products and services for our business clients, upgraded cash management and electronic funds transfer features, and a new business credit card program to provide cardholders with an industry-leading digital experience.
22 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
Obsessed with your success
Table of Contents
Maintain a foundation of trust
Manage our impact responsibly
Supplemental reporting
Overview
Appendices
My relationship manager gives me a sense of optimism and success. I feel like I am very informed and smarter when I speak to them. They work hard to accomplish our goals.” - CWB client Our relationship manager really tries to understand our business. He doesn’t take shortcuts and really believes in our business. He feels like he is a part of the team.” - CWB client
Mark Halston, President, Ironman Properties Ltd. & Ironman Automotive Ltd. Chris Greenway, CWB Financial Group
Strengthening our client experience with the launch of CWB Wealth
In 2022, we launched CWB Wealth, our new national brand for private wealth advisory services. The launch further integrates our acquired wealth management operations under one brand and positions CWB Wealth to provide a differentiated client experience in Canadian private wealth advisory services. Uniting our offering under a harmonized brand allows us to leverage the unique strengths that each legacy firm brings to CWB Wealth to meet the complex financial needs of our core client market - successful business families, business executives, and employees of the businesses we serve.
23 2022 SUSTAINABILITY REPORT AND PUBLIC ACCOUNTABILITY STATEMENT
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